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Affordable Housing SPD comments

Jerry Flynn comments on the draft Affordable Housing SPD (please note that the proposed changes are in bold).

<p1.2.3 The Housing Requirements Study (2009) identifies a much greater need for social rented housing than for intermediate – 6,458 social rented units against 1,789 intermediate units (Fig 107). Further, there is a surplus for all sizes of intermediate units, except 3 bed units. This is not reflected in the SPD as drafted. I suggest that the end of the second sentence is reworded to read ‘…….that there is a considerable need for more affordable housing, particularly including both social rented. and intermediate housing’.

1.3.3 The reference to current proposals for changes to affordable housing should be amplified to give a better idea of what the likely, or possible, consequences will be.

1.4.2 The inclusion of student housing developments amongst those that will be required to provide affordable housing is welcome. The HRS 2009 notes ‘….local authorities will need to maximise affordable housing delivery wherever opportunities arise’ (7.24); student developments provide just such an opportunity, given that in London Southwark has the second highest number of schemes in the development pipeline in London (para 2.3 Southwark Student Housing Study July 2010). Further, if mixed and cohesive communities are to be created student developments cannot be treated as an exception.

2.3 If I understand it correctly there seems to be an affordability gap for households with annual incomes between £18,100 and £29,515. Households with income greater than £18,100 are not eligible for social rented housing (2.3.2; Table 1), yet developers will not be required to provide intermediate housing for those earning less than £29,515 (Table 2). This gap should be closed and developers required to provide intermediate units that are affordable to households on incomes of £18,100.

2.4 The Council’s submission that the new affordable rent of 80% market rents may not work in Southwark understates the case (2.4.2). HRS 2009 states that even the cheapest properties in the private sector typically cost two to four times housing corporation target rents (3.59; Fig 82). There can be little doubt that there will be no affordable housing in any meaningful sense if future developments are allowed to use this new category to fulfil their affordable housing obligations. The SPD should amplify this point and a redrafted SDP should be resubmitted for public consultation once final national policy is in place.

4.2.9 Bullet point 2 of Policy 4.4, that affordable housing should be indistinguishable from private housing development, is not being followed in practice, which indicates that the monitoring of the policy is inadequate. (An example is the recent development along Crampton St, where the affordable housing element is clearly identifiable by its iron balconies; the private homes have larger and more attractive wooden balconies).

Planning applications for larger developments often stipulate that affordable housing must have separate entrances or cores, for management purposes or other reasons (eg Oakmayne Plaza). This necessarily increases the cost of the development and allows the developer to plead that the onsite provision of affordable housing is not financially viable, undermining policy efforts to increase its amount and create mixed and cohesive communities.

The policy should therefore state that where affordable housing is required in a development it cannot include separate blocks that each consist exclusively of private or affordable housing units. It should further stipulate that the specifications for all elements of the housing units of the same size should be identical.

5.3.1 Please see my observations and comment above on this point. I propose that this para should be re-drafted to read ‘Affordable housing is to be integrated with market housing through identical specifications of design and shared and equal access to all communal facilities, including lifts, corridors and other means of entry and exit’.

5.3.2 ‘Pepper-potting’ is now common on council estates as a consequence of the right-to-buy; owner-occupiers live right beside council tenants and the local authorities have devised systems to manage this; private developers and their partners must do the same. There is also no apparent reason why having different housing tenures alongside each other should increase costs of any kind, if the units, facilities and services are identical – it seems more likely that it is when differences are introduced that costs rise. Integrating the housing tenures and keeping the units and services identical is therefore the key to keeping the housing costs down and maintaining the viability of the development and thus ensuring the maximum amount of social housing. This paragraph should be redrafted to reflect this;

The physical integration of affordable housing among market housing (otherwise known as pepper-potting) will normally be required. In exceptional circumstances applicants must justify why the affordable housing cannot be physically integrated amongst private housing. Any costs associated with pepper-potting should be addressed by efficient systems of management.

This issue mostly occurs in the development of flats. In these circumstances we suggest that market and affordable housing could be vertically grouped to keep housing costs affordable. There must be no difference in the appearance and quality of affordable units and private units.

Affordable and private tenants must have equal access to communal facilities such as shared gardens and parking areas. All housing must be carefully designed so it can be easily maintained. High service charges and maintenance costs associated with badly designed developments can affect the viability of the development and the affordability of housing for residents.

7.3.12 Core Strategy policy 6 paragraph has no consistency and makes little sense on this point. While it requires net affordable housing targets for the borough, it allows gross targets for the different action areas, where most of the development and affordable housing opportunities are located. This disguises the actual loss of affordable housing in action/regeneration areas and the loss of affordable housing opportunities. The affordable housing targets for both the borough and action/regeneration areas should be expressed as net figures.

7.3.13 I understand that the net loss of affordable housing in any regeneration scheme is contrary to the London Plan, hence the exception agreed with the Mayor referred to in this paragraph. This exception is perverse given that Southwark admits it cannot meet all the need for affordable housing (5.60 Core Strategy). No reason is given for preferring the priority of creating ‘mixed and balanced communities’ over providing affordable housing; further a lack of affordable housing undermines a main condition of any balanced community. This paragraph should be redrafted to be in accordance with the London Plan or, failing that, amended to allow loss of affordable housing in any estate regeneration scheme only if the borough affordable housing target is otherwise met for each year of the scheme’s duration.

Community Council planning focus group

Council is running a focus group to discuss community council planning meetings, mainly, we understand, in the context of cost-cutting and not democratisation of the processes.
They are hoping to have 2-3 people from each community council area, although it is yet to be confirmed whether anyone in Camberwell received any notifications from the community council administrators. There certainly isn't any information about the focus group on the council's website.
The focus group will take place on Wednesday 7th September, from 14:30 – 16:00 in room GO1c, in Tooley Street.
If you would like to attend, please contact your local community council development officer

Gala bingo hall again and again, part 1

In this part of the objection I will argue that the proposed change of use is entirely inappropriate for the site in its local, historical and present context and that it fails to comply with a number of national, London and local planning policies.

If you find any of my comments helpful, feel free to use them and/or copy and paste and send your responses to This email address is being protected from spambots. You need JavaScript enabled to view it.at Southwark Council quoting reference 10/AP/3240 which is the application for change of use. If you do not wish for your personal details (email/home address) to be publicly posted on the Council's website, we advise you ask them to remove your personal details from the published document.

Canada Water Area Action Plan public hearing schedule

Draft schedule for the public hearing on Canada Water Area Action Plan (CWAAP) is below. All the documents relating to the CWAAP can be downloaded from the council's website.

Canada Water Area Action Plan public hearing issues and matters

Canada Water Area Action Plan public hearing is scheduled for January 2011. Background documents can be downloaded from Southwark Council's website.

Camberwell Village Hall reponse: Part 3

The attachment is the repsonses to the Camberwell Village Hall petition.

Tom and James are much appreciated for the vast amount of effort they have put into this campaign over the last five months and will be for quite some time to come.

Everyone who has voiced their opinion, either for or against, on the change of use planning application congratulate yourselves for showing Camberwell does have residents who want to make changes in the area

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